Date: March 23, 2017

Issue: Corporate Governance;


Filing Type: Letter

Description: The Coalition welcomes the opportunity to comment on the final
rules issued by the Securities and Exchange Commission (the “SEC” or
“Commission”) under Section 953(b) of the Dodd-Frank Wall Street Reform and
Consumer Protection Act (“Dodd-Frank”), concerning the pay ratio rule.
The Coalition fundamentally believes that the pay ratio rule:

  • Does nothing to advance the Commission’s tripartite mission of protecting investors, maintaining fair, orderly, and efficient markets, and facilitating capital formation;
  • Fails to provide investors with any kind of material information to inform their decision making;
  • Contributes to the phenomenon of “information overload” and makes the public company model even less attractive and;
  • Imposes billions of dollars in costs upon public companies and their shareholders, distracts management from their core responsibilities, and provides no benefit to the American capital markets.

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